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Is Honesty the Best Policy in Foodborne Illness Investigations?

One of the most important protections we have against foodborne illness is our disease-surveillance systems. These systems field reports from widespread sources and may include disease-reporting registries, local and state health departments, the Centers for Disease Control and Prevention (CDC), and utilize active outreach to clinicians and hospitals.

The data collected often reveal associations in time, place, person, and illness in the population. Such can lead an investigator to valuable information to stop outbreaks from continuing, but only if the data is accurate, properly understood, and acted upon.

Outbreaks usually have a defined course and chain of events, and when data are plotted, they will reveal onset dates, peaks and the tailing away of cases. The data may also reveal the immediate source of a contaminated food, allowing consumers to protect themselves if the information is made public. The epidemiologist is in a critical situation when they have data that supports a hypothesis that an outbreak of disease is occurring.

As surveillance improves, thanks to better diagnostics and more effective reporting, we now see a marked increase in foodborne illness outbreaks that come to light through an epidemiological approach.

Historically, the most fundamental finding in a foodborne outbreak investigation is the isolation of the causative organism from both victims and foods. When this detail is at hand, they provide strong associations between victims and likely causes. In such cases, the epidemiologist has traditionally made that information public. This allows the public to make a choice, helps in further case finding, and allows the removal of affected products.

But the gold standard is difficult to obtain, and only a fraction of the actual foodborne outbreaks known to occur have a confirmed cause; this success being dependent on the shelf life of the food items, the ability to isolate the pathogens from food, and other factors.

The Peanut Corporation of America (PCA) caused a deadly and long-lasting outbreak with its peanut butter products in 2007-2008. Cases continued over several weeks before the CDC — in tandem with Team Diarrhea — made the associations with King Nut, and eventually PCA. The question was repeatedly asked, “Why did it take so long for the outbreak to be recognized?” The delay drew the attention of some notables in epidemiology and led to criticism in CDC’s epidemiological approach.

On the other hand, recently a state health investigator pointed to a Salmonella outbreak in Cantaloupe without the causative agent being isolated. A detailed trace-back of cases led to strong associations between the importer and those made ill. The importer, who was named in the press, sued the epidemiologist, but later dropped the suit.

These shots across the bow of epidemiology are still apparently resounding.

Now we learn CDC and health departments in 10 states investigated an outbreak of 70 cases of Salmonella, but kept the process secret, and now will not reveal the name of the implicated restaurant. While it is clear that epidemiology as a science has limitations, the data can also be convincing, especially when there are clusters of cases that point to a common immediate source. Withholding the name of the immediate source, even when specific foods cannot be identified, does little to protect the public from immediate hazards or to find solutions to future occurrences.

In the nationwide US outbreak of peppers/tomatoes in 2008, associations between tomatoes and cases became less and less likely as more cases of salmonellosis in persons eating peppers came to light. The effect on the tomato industry was dramatic, with losses in the untold millions.

When public health officials make mistakes in foodborne outbreaks, the industry suffers and the political fallout is extreme. To the extent that they do not act to protect the public, they fail their mission. We should not forget that local officials are closely tied to their communities in many ways. Local health departments rely on revenue generated from the local food service industry. After many years, bonds form between local public health agencies and industry, naturally, and out of necessity. When a regulator is compelled by the evidence and must take on the health protection role, he can find it painful. The wrong word — “strawberries instead of blueberries” can cost one their position. Therefore, it is not unreasonable for the regulator to be stuck in a “damned if you do, and damned if you don’t” situation, especially if he is a local.

In the end, honesty is the best policy during any outbreak of disease. When the investigator is guided by a careful analysis of data, an honest presentation of the facts and truthful explanation is all we can ask for. Consumers demand no less from CDC. Perhaps there needs to be “whistleblower protections” for CDC from lawsuits (ironically, this protection is afforded now by the FSMA-but only to workers in FDA-regulated facilities).

It’s in the best interest of everyone to work together in crisis times like these in food safety. The public understands and forgives a mistake when it occurs out an abundance of caution to protect them, but there is no forgiveness for a failure to inform them and they suffer as a result. The failure of CDC to name names is preventing the redress that victims rightfully have for damages and also reflects the power industry has to keep our investigators silent.

___Roy Costa is the founder and owner of the consulting firm Environ Health Associates, Inc. Mr. Costa is a registered professional sanitarian with 30 years of environmental heath practice in the academic, government and private sectors. Mr. Costa is an educator and food safety trainer with International experience in a number of countries.

In the summer of 2010, curiosity persuaded me to visit six local super markets in the Michigan area, purchase six different bunches of celery and test each for the presence or absence of Listeria at an analytical sensitivity of 1 CFU/10 grams. I found that two out of my six samples showed presumptive evidence of Listeria contamination. Of course I felt an ethical duty to inform the stores involved as well as the Michigan Department of Health and Michigan Department of Agriculture, whose jurisdiction includes food sold at the retail level. Both state agencies told me how underfunded and helpless they were. Half a dozen store managers told me that their job was to sell the foods that were delivered to their loading docks and that safety issues were “Corporate’s Problem.” If finding a pathogen lurking in a food (and especially one often eaten raw) is a “gold standard,” as you say, in an epidemiological investigation, does that only apply if people are getting sick and/or dying? If the answer to that question is “Yes,” then what is safety testing really all about?

Roy, your suggestion above that “Honesty is the Best Policy” frequently falls on deaf ears at USDA/FSIS. Likewise, your statement above “Historically, the most fundamental finding in a foodborne outbreak investigation is the isolation of the causative organism from both victims and food” is frequently precluded from FSIS’ radar. Subsequent to the agency’s investigative mishandling of 4 lab positives for the presence of E.coli O157:H7 at my firm ten years ago, I quickly discovered that FSIS prevents the truth from being documented, let alone revealed. Since then, I’ve visited with many other meat plant owners who have conducted recalls for products adulterated with E.coli. They have all agreed, bar none, that if bona fide evidence existed proving that the E.coli was present in meat purchased from a large source slaughter provider, FSIS investigators had ZERO interest in documenting the evidence, and refused suggestions to perform a traceback to the SOURCE. FSIS’ response has been to mandate that the downstream, further processing grinding plants conduct HACCP reassessments and implement corrective actions to prevent recurrences. This agency ploy essentially insulates the source from accountability, pretending that changes in HACCP Plans at downstream plants will force the true SOURCE, that is, the slaughter plant, to initiate changes which will prevent the slaughter plant from introducing E.coli into the food chain in the future.
Roy, this is science, FSIS style.
This is but another example of your truism above when you stated “…..reflects the power industry has to keep our investigators silent”. Those wielding power over congressional funding must decide if FSIS’ primary emphasis should be to protect public health, or to protect the largest slaughter plants. As long as FSIS adroitly avoids determining the true Source, and of course circumventing the need to Force the Source to clean up its act, public health continues to be imperiled.
Roy, my perception is that your belief and mine regarding (a) Honesty and (b) Determining the Causative Source are deemed as heresy at FSIS. As such, the agency is actually more of an enemy than pathogens themselves, as FSIS issues a Pass card to the source.
John Munsell

Roy, your suggestion above that “Honesty is the Best Policy” frequently falls on deaf ears at USDA/FSIS. Likewise, your statement above “Historically, the most fundamental finding in a foodborne outbreak investigation is the isolation of the causative organism from both victims and food” is frequently precluded from FSIS’ radar. Subsequent to the agency’s investigative mishandling of 4 lab positives for the presence of E.coli O157:H7 at my firm ten years ago, I quickly discovered that FSIS prevents the truth from being documented, let alone revealed. Since then, I’ve visited with many other meat plant owners who have conducted recalls for products adulterated with E.coli. They have all agreed, bar none, that if bona fide evidence existed proving that the E.coli was present in meat purchased from a large source slaughter provider, FSIS investigators had ZERO interest in documenting the evidence, and refused suggestions to perform a traceback to the SOURCE. FSIS’ response has been to mandate that the downstream, further processing grinding plants conduct HACCP reassessments and implement corrective actions to prevent recurrences. This agency ploy essentially insulates the source from accountability, pretending that changes in HACCP Plans at downstream plants will force the true SOURCE, that is, the slaughter plant, to initiate changes which will prevent the slaughter plant from introducing E.coli into the food chain in the future.
Roy, this is science, FSIS style.
This is but another example of your truism above when you stated “…..reflects the power industry has to keep our investigators silent”. Those wielding power over congressional funding must decide if FSIS’ primary emphasis should be to protect public health, or to protect the largest slaughter plants. As long as FSIS adroitly avoids determining the true Source, and of course circumventing the need to Force the Source to clean up its act, public health continues to be imperiled.
Roy, my perception is that your belief and mine regarding (a) Honesty and (b) Determining the Causative Source are deemed as heresy at FSIS. As such, the agency is actually more of an enemy than pathogens themselves, as FSIS issues a Pass card to the source.
John Munsell